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Chicago Lock Co. v. Fanberg

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Facts: Chicago Lock Co. manufactured Ace tubular locks. Each lock has a serial number which corresponds to that lock’s key code. Fanburg, a locksmith, compiled a list of corresponding key codes and serial numbers. He compiled this list from picking customers’ locks and grinding keys for them. He published an advertisement in a locksmith trade magazine requesting that other locksmiths submit their lists of lock serial numbers and corresponding key codes in exchange for a copy of a compilation book with all known key codes and corresponding serial numbers. Chicago Lock Co. filed suit to enjoin publication of compilation, citing trade secrets.

Procedural History: Plaintiff filed suit for trade secret protection, trademark infringement, and unfair competition. The district court granted summary judgment to Plaintiff, saying that Defendant used improper means to acquire Plaintiff’s trade secrets. The other claims were dismissed.

Issue: Was Fanburg's means of obtaining the information improper?

Arguments: Chicago Lock Co. argued that receiving compilations from various locksmiths and publishing was an unfair business practice and improper means.

Holding: Not improper.

Reasons: Reverse engineering to obtain the information was permissible, and after that the company has no more monopoly power or control over that information. The serial numbers and corresponding key codes can be freely disseminated and used. There was also no duty owed by the locksmiths to the company to not disclose the information.

Judgment: Reversed.